Effective Date: 1 March 2019
If you have any questions or comments about the Policy, please contact us at email@example.com. This Policy is incorporated into and is subject to the CityWink Terms & Conditions, which can be accessed at www.citywink.ug/terms-conditions. Your use of the Product and/or Services and any personal data you provide on the Product remains subject to the terms of the Policy and CityWink’s Terms & Conditions.
A. Collection of Your Personal Data
- COLLECTION OF PERSONAL DATA
We collect personal data from Service Providers offering their products and services as well as from consumers searching for those Service Providers. Both consumers and Service Providers are required to create an account to be able to access certain portions of our Product, such as to submit questions, participate in polls or surveys, to request a quote, to submit a bid in response to a quote, and request information. The type of personal data that we collect from you varies based on your particular interaction with our Product.
We collect your personal data in the course of your dealings with us including:
- your personal details, including details relating directly or indirectly to other person(s) who may be identified from the data, including but not limited to your name, age, identity card number or passport number, correspondence address, office address, gender, date of birth, contact information, e-mail address, mobile number, house number, facsimile number, and office number;
- the contents of chats between users and Service Providers;
- the contents of all information obtained from the membership and/or forms and/or documents collected by us; and/or
- other information (collectively, “Personal Data”).
Consumers: During the Account registration process, we will collect information such as your name, postal code, and email address. You also may provide us with your telephone number, mailing address, and demographic information. We may also collect Personal Data that you post in your Offer, Profile, Wants, or Feedback, and any comments or discussions you post in any blog, chat room, or other correspondence site on the Product, or any comments you provide during dispute resolution with other users of the Product.
Service Providers: If you are a service provider and would like to post any information about yourself, we will require you to register for an Account. During the Account registration process, we will collect your business name, telephone number, address, postal code, travel preferences, a description of your services, a headline for your profile, first and last name, and email address. In addition, you may, but are not required to, provide other content or information about your business, including photographs and videos. We also may collect payment information, such as credit card information, from you.
If we deem it necessary, in our sole and absolute discretion, we may also ask for and collect supplemental information from third parties, such as information about your credit from a credit bureau (to the extent permitted by law), or information to verify any identification details you provide during registration.
- COLLECTION OF PERSONAL DATA FROM SOCIAL NETWORKING SITES
You may log into our Product through your Facebook account. If you do so, you must enter the email address and password that you use for your Facebook account. We will ask that you grant us permission to access and collect your Facebook basic information (this includes your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other information you have set to public on your Facebook account). If you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public.
We store the information that we receive from Facebook with other information that we collect from you or receive about you.
Cookies. We and our third party service providers collect information from you by using cookies. A cookie is a small file stored on user’s computer hard drive containing information about the user. The cookie helps us analyze web traffic or informs you about your use of a particular Product. Cookies allow web applications to respond to you as an individual, tailoring its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. When you visit the Product, we may send one or more cookies (i.e., a small text file containing a string of alphanumeric characters) to your computer that identifies your browser.
Disabling Cookies. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you disable cookies you may be prevented from taking full advantage of the Product because it may not function properly if the ability to accept cookies is disabled.
B. How CityWink Uses the Information We Collect
- HOW PERSONAL DATA IS USED
We collect your Personal Data and aggregate information about the use of our Product and Services to better understand your needs and to provide you with a better Product experience. Specifically, we may use your Personal Data for the following purposes, including but not limited to:
To provide our Services to you, including registering you for our Services, verifying your identity and authority to use our Services, and to otherwise enable you to use our Product and our Services;
For customer support and to respond to your inquiries;
For internal record-keeping purposes;
To process billing and payment, including sharing with other third party payment gateways in connection with Product and/or CityWink’s products and Services;
To improve and maintain our Product and our Services (for example, we track information entered through the “Search” function; this helps us determine which areas of our Product users like best and areas that we may want to enhance; we also will use for trouble-shooting purposes, where applicable);
To periodically send promotional emails to the email address you provide regarding new products from CityWink, special offers from CityWink or other information about CityWink that we think you may find interesting;
To contact you via email, telephone, facsimile or mail, or, where requested, by text message, to deliver certain services or information you have requested;
For CityWink’s market research purposes, including, but not limited to, the customization of the Product according to your interests;
We may use your demographic information (i.e., age, postal code, residential and commercial addresses, and other various data) to more effectively facilitate the promotion of goods and services to appropriate target audiences and for other research and analytical purposes;
To resolve disputes, to protect ourselves and other users of our Product and Services, and to enforce our Terms & Conditions;
We also may compare Personal Data collected through the Product and Services to verify its accuracy with Personal Data collected from third parties;
We may combine aggregate data with the Personal Data we collect about you; and
For any purpose incidental, ancillary or in furtherance to the abovementioned purposes (collectively referred to as “Purposes”).
C. Electronic Newsletters, Invitations, Polls and Surveys
At our sole discretion, CityWink may offer any of the following free services on the Product, which you may select to use or receive at your option. Certain of the following services may require you to provide additional Personal Data as detailed below:
- ELECTRONIC NEWSLETTERS
We may offer a free electronic newsletter to users. We will gather the email addresses of users who sign up for CityWink for the newsletter mailing list. Users may remove themselves from this mailing list by opting out of receiving newsletters during the registration process, by following the link provided in each newsletter that points users to a subscription management page where the user can unsubscribe from receiving newsletters or by changing their preferences in their Profile Settings page.
- “SEND TO A FRIEND”
Our Product users can voluntarily choose to electronically forward a link, page, or document to someone else by clicking “send to a friend.” To do so, the user must provide his or her email address or phone number, as well as the email address or phone number of the recipient. The user’s email address and phone number is used only in the case of transmission errors and, of course, to let the recipient know who sent the email. The information is not used for any other purpose.
We may offer interactive polls to users so they can easily share their opinions with other users and see what our audience thinks about important issues, Services, and/or the Product. Opinions or other responses to polls are aggregated and are not identifiable to any particular user. We may use a system to “tag” users after they have voted, so they can vote only once on a particular question. This tag is not correlated with information about individual users.
We may conduct user surveys from time to time to better target our content to our Product users. We will not share individual responses from these surveys with any third party. We will share aggregate data with third party service providers, partners, and other third parties. We also will post aggregate data containing survey responses on our Product; that data may be viewed and downloaded by other users of our Product.
D. Children’s Privacy
Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with Personal Data, we may delete such information from our systems.
We employ procedural and technological security measures, which are reasonably and practically designed to help protect your Personal Data from loss, misuse, modification, unauthorised or accidental access or disclosure, alteration or destruction.. We ensure that confidentiality safeguards have been put in place to ensure your rights to personal data protection remains unaffected. We protect your Personal Data by: (a) restricting access to Personal Data; and (b) maintaining and implementing measures to prevent unauthorised computer access, which includes using encryption, passwords. No security measures, however, are 100% complete. Therefore, we do not promise and cannot guarantee, and thus you should not expect, that your Personal Data or private communications will not be collected and used by others. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. CityWink is not responsible for the unauthorized use of your information or for any lost, stolen, compromised passwords, or for any activity on your Account via unauthorized password activity.
As and when necessary, we may share and/or disclose the information that we collect about you, including your Personal Data, as follows:
- INFORMATION DISCLOSED TO PROTECT US AND OTHERS
We may disclose your Personal Data to prevent an emergency, protect or enforce our rights, enforce our Terms & Conditions and/or to protect the safety of users of our Product and our Services or protect or enforce the rights of a third party, or as required by law.
- INFORMATION DISCLOSED TO THIRD PARTY SERVICE PROVIDERS AND BUSINESS PARTNERS
We may contract with various third parties for the provision and maintenance of the Product, Services and our business operations, and CityWink may need to share your Personal Data and data generated by cookies and aggregate information (collectively, “information”) with these vendors and service agencies. For example, we may provide your information to a credit card processing company to process your payment. The vendors and service agencies will not receive any right to use your Personal Data beyond what is necessary to perform its obligations to provide the Services to you. If you complete a survey, we also may share your information with the survey provider; if we offer a survey in conjunction with another entity, we also will disclose the results to that entity.
- DISCLOSURE TO NON-AFFILIATED THIRD PARTIES IN FURTHERANCE OF YOUR REQUEST
Your request for services may be shared with third party Products with whom we have a contractual relationship in order to provide your request with maximum exposure. The post on the third party Product will include the details of your request, including your location, but will not include your last name. Interested bidders, however, will be able to click on your request on such third party site, and will be directed to our Product where they will have access to your first name and the first letter of your last name, as would any other service provider on our Product interested in bidding on your request.
- DISCLOSURE TO OTHER USERS OF OUR PRODUCT
If you are a service professional, the information that you post (other than your payment information) is available to other users of our Product and our Services. Comments that users post to our Product also will be available to other visitors to our Product (see our discussion of User Generated Content below). In addition, we will post the results (in aggregate form) of surveys to our Product. If you are a consumer, your first name plus first initial of your last name, zip code, as well as the details of your request, are available to all visitors to our Product. Bidding Service Providers also will be permitted to see the consumer’s full name and telephone number. When you submit a request for services, Service Providers will be able to see details relating to your request, in order for them to bid on, and provide services, related to your request. This personal data may include (but is not limited to) your name; your service location; and your contact details (including your phone number).
- INFORMATION DISCLOSED TO LAW ENFORCEMENT OR GOVERNMENT OFFICIALS
We will disclose your information, including, without limitation, your name, city, state, telephone number, email address, user ID history, quoting and listing history, and fraud complaints, to law enforcement or other government officials if we are required to do so by law, regulation or other government authority or otherwise in cooperation with an investigation of a governmental authority.
- IN THE EVENT OF A CHANGE OF CONTROL OR BANKRUPTCY
In the event that CityWink undergoes a change in control, including, without limitation, a merger or sale of all or substantially all of CityWink’s assets to which this Product relates or other corporate reorganization in which CityWink participates, and is thus merged with or acquired by a third party entity (a “Successor”), CityWink hereby reserves the right to transfer the information we have collected from the users of the Product and/or Services to such Successor.
In addition, in the event of CityWink’s bankruptcy, reorganization, receivership, or assignment for the benefit of creditors, or the application or laws or equitable principles affecting creditors’ rights generally, CityWink may not be able to control how your information is transferred, used, or treated and reserves the right to transfer the information we have collected from the users of the Product and/or Services to non-affiliated third parties in such event.
- INFORMATION DISCLOSED AT YOUR REQUEST
We may share your Personal Data with other Registered Users to whom you explicitly ask us to send your information or if you explicitly consent to such disclosure upon receipt of a specific Service. For instance, when you contract for a specific Service with another Registered User, CityWink will send that Registered User a notice that includes the Personal Data that you have chosen to allow CityWink to reveal to users with whom you contract.
G. Links to External Products
H. Retention Standard
Any Personal Data shall not be kept longer than is necessary for the fulfilment of the Purposes as set forth in section B above. CityWink is committed to take all reasonable steps to ensure that all Personal Data is destroyed or permanently deleted when it is no longer required for the Purposes for which it was to be processed.
I. Updating, Deleting and Correcting Your Personal Data
CityWink is committed to take reasonable steps to ensure that the Personal Data is accurate, complete, not misleading and kept up-to-date by having regard to the Purposes for which the Personal Data was collected and further processed. Should you made aware of any inaccurate, incomplete and misleading Personal Data or where the Personal Data provided to us earlier have become incorrect and out of date, kindly contact us at firstname.lastname@example.org.
You may choose to restrict the collection or use of your Personal Data in the following ways:
You can review, correct and delete your Personal Data by logging into the Product and navigating to your preferences page in “Your Profile” (or similar screen/page). You must promptly update your Personal Data if it changes or is inaccurate. Typically, we will not manually alter your Personal Data because it is very difficult to verify your identity remotely. Nonetheless, upon your request we will close your Account and remove your Personal Data from view as soon as reasonably possible based on your Account activity and in accordance with applicable law. We do retain information from closed Accounts in order to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations of any Registered User, enforce our Terms & Conditions, and take any other actions otherwise permitted by law that we deem necessary in our sole and absolute discretion. You should understand, however, that once you publicly post a Request, Offer, Want, Feedback, or any other information onto the Product, you may not be able to change or remove it. Once we have deleted or removed your Account, you agree that CityWink shall not be responsible for any Personal Data that was not included within your deleted and/or removed Account that remains on the Product.
J. What Choices Do I Have Regarding Use of My Personal Data?
We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your Account or any Services you have requested or received from us.
K. Third-Party Ad Networks
L. Your Full Name and Use of CityWink Information
- YOUR FULL NAME
As a Registered User of the Product you will select a Full Name during the registration process. All of your activities on the Product will be traceable to your Full Name. Certain other people, including other Registered Users with whom you have transacted business via the Product, can see a large part of your activity on the Product. If you book a service with a Registered User, cancel a scheduled service with a Registered User, receive an offer on your posted service from a Registered User, or have posted a service, CityWink may send a notice to you or the appropriate Registered User that includes your Full Name. Thus, if you associate your real name with your Full Name, the people to whom you have revealed your name may be able to personally identify your Product activities.
- USING INFORMATION FROM CITYWINK
The Product facilitates your sharing of Personal Data with others in order to negotiate, provide, and use the Services. If you agree to contract for a service with another Registered User, you may need to reveal your name, email, phone number, or personal address to that individual so that the service may be performed. Please respect the privacy of others. You agree to use the information of other users solely for the following purposes: (a) CityWink-transaction-related purposes; and (b) using Services offered through the Product.
- ACCOUNT PROTECTION
Your password is the key to your Account. When creating your password you should use unique numbers, letters, special characters, and combinations thereof. In addition, DO NOT disclose your password to anyone. If you do share your password or your Personal Data with others, you are solely responsible for all actions taken via your Account. If you lose control of your password, you may lose substantial control over your Personal Data and be subject to legally binding actions taken on your behalf. Thus, IF YOUR PASSWORD HAS BEEN COMPROMISED FOR ANY REASON, YOU MUST IMMEDIATELY NOTIFY CITYWINK TO CHANGE YOUR PASSWORD.
M. User Generated Content
We invite you to post content on our Product, including your comments, feedback, pictures, and any other information that you would like to be available on our Product. If you post content to our Product, all of the information that you post will be available to all visitors to our Product. If you post your own content on our Product or Services, your posting may become public and CityWink cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy. We may also use User Generated Content, such as reviews about our product or Service Providers, on for the purposes of marketing our Services and you consent to this being used.
By accessing or using our Services and/or Product, you consent to the collections and use of the Personal Data by CityWink in the ways described hereinabove (which may change from time to time) unless and until you inform CityWink to the contrary here.
THIS POLICY IS CURRENT AS OF THE EFFECTIVE DATE SET FORTH ABOVE. CITYWINK MAY, IN ITS SOLE AND ABSOLUTE DISCRETION, CHANGE, AMEND AND/OR VARY THIS POLICY FROM TIME TO TIME. CITYWINK WILL PUBLISH THE UPDATED POLICY ON THE PRODUCT ON THIS PAGE. CITYWINK ENCOURAGES YOU TO REVIEWTHIS POLICY REGULARLY FOR ANY CHANGES MADE. BY ACCESSING OR CONTINUING TO USE OUR SERVICES AND/OR PRODUCT AFTER ANY CHANGES TO THIS POLICY, YOU AGREE THAT YOU HAVE READ, UNDERSTOOD AND AGREE TO BE BOUND BY THIS POLICY INCLUDING ANY CHANGES, AMENDMENTS AND/OR VARIATIONS MADE TO IT.